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Return to Comments
Standards of Conduct--Reproposed NPRM
Type: Regulation
Federal Register Document Type: Reproposed
Revise existing standards of conduct regulations in Subpart A, Part 612, and consider a more principle-based rule to facilitate a sound standards of conduct program at System institutions.

Text of Comment Letter
Dear Mr. Mardock
The present regulation appears adequate and complete, allowed for the building of consistent practices with clarity, and has presented a focus purpose. Therefore, adopting the new proposed regulation in its entirety may undermine the very purpose and process for the existing standards of conduct protocol.

We suggest you consider targeted revisions to the existing regulation rather than the broad sweeping changes within the proposed rule. Of particular concern to me as a farmer director is the overly burdensome structure of the regulation in terms of reporting, tracking and materiality standards. Further, the application of the regulation to outside agents without clearer definitions will certainly make it more difficult to administer and do business.

I am appreciative to have the opportunity to provide a commeny to the proposed regulation on such an important topic, and hope that my suggestion to not over regulate a matter that is already fundamental in nature. The existing regulations have served us well.

Sincerely, Darl Evers

Director at GreenStone